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Privacy Policy

KELLY + PARTNERS is committed to treating the personal information
we collect in accordance with the Australian Privacy Principles in the
Privacy Act 1988 (Cth) (Privacy Act). This policy sets out how Kelly
Partners handles personal information.

This privacy policy does not apply to personal information
collected by Kelly Partners that is exempted under the Privacy Act, for
example employee records.

Our privacy policy will be reviewed regularly to take account
of changes in legislation, technology, and our operations and
practices. We aim to ensure the policy is appropriate to the changing
environment. We will inform you of any changes we make to this privacy
policy as necessary.

Our privacy policy is based on openness about how we use and protect your information.

Requesting a copy of KELLY + PARTNERS Privacy Policy:

Our privacy policy is available by following links to the
policy on our website. However, on request, we may be able to provide
you with a copy of the policy in an alternate format. If you have any
enquiries or would like to make a request for a copy of the policy,
please contact our Privacy Officer (refer to contact details below).

We only collect, hold, use and disclose personal information which
is reasonably necessary to ensure that we are able to provide you with
the products and services that are appropriate to your needs. We will
outline to you when you engage our services the purposes for which we
will collect, hold, use and disclose your personal information.

2. Kinds of personal information KELLY + PARTNERS collects:

Due to the nature of the products and services we provide, and the
requirements of legislation and regulations, we ask for a range of
personal information from our customers.

The types of personal information we may collect can include details such as:

It may be necessary in some circumstances for KELLY +
PARTNERS to collect sensitive information about you in order to provide
specific services. The types of sensitive information we may collect
include:

Health status;

Ethnic origin;

Details of any membership/s to professional associations;

Criminal record.

You have a right to refuse to provide us with your personal
information or to anonymity or the use of a pseudonym. However, if you
do refuse to provide such information, or request the use of anonymity
or a pseudonym we may be unable to complete or fulfil the purpose for
which such information was collected, including providing you or our
clients with the services we were engaged to perform.

3. Collection, holding, using and disclosing of personal information:

(a) Collection – General:

When we collect, hold, use and disclose personal or sensitive
information it must be done through lawful and fair means.
Consent must be obtained to collect, hold, use and disclose personal
information.
We are not required to obtain your consent to collect, hold, use of
disclose your personal or sensitive information if the collection is
required or authorised by or under an Australian law or a court/tribunal
order.
There are other exceptions to the requirement of obtaining your consent
in accordance with the Australian Privacy Principles. If you would like
more information on these requirements, please contact our Privacy
Officer.

(b) Methods of collection:

KELLY + PARTNERS use a variety of formats for the collection of personal and sensitive information. These include:

Requiring clients to complete a Client Profile or other forms;

Receipt of emails, letters and other correspondence;

Telephone calls;

Appointments in person;

Publicly available records;

Through a customer’s personal representative;

Through use of our website, such as via contact mailboxes or
online enquiry forms, or through the registration process (see more
information about ‘web analytics’ in Clause 2).

In every circumstance we will attempt to obtain such personal and
sensitive information directly from you. If that is unreasonable or
impracticable, we will attempt to obtain such information from other
sources in accordance with Clause 3(a) above.

(c) Collection of someone else’s personal information:

ou should only provide us with someone else’s personal information
where you have their express consent to do so and it is for the purpose
of us providing services to you. Matters in this policy should be
communicated to any person whose information you collect and provide to
us.

Unsolicited personal information:

There may be circumstances where we are provided with personal
information which we did not actively seek. An example may be
misdirected mail, or an excess of documents provided to us by clients.

In such situations, our Privacy Officer will make a determination on
whether we could have obtained the information lawfully in accordance
with the APPs. If the information was not lawfully obtained it will be
destroyed or de-identified. We will try to notify the relevant person,
whose information has been mistakenly received, if this situation
arises.

4. Security of personal information

Safeguarding the privacy of your information is important to us. We
hold personal information in a combination of secure computer storage
facilities and paper based files, and take steps to protect the personal
information we hold from misuse, loss, interference, unauthorised
access, modification or disclosure.

KELLY + PARTNERS trains its employees carefully on handling personal information and confidentiality of such information.

Once we have no purpose for holding your personal information, we
will take all reasonable steps to destroy or de-identify the
information.

5. Disclosure of personal information overseas and sharing personal
information amongst and within the KELLY + PARTNERS Group network

(a) Disclosure amongst and within the KELLY + PARTNERS Group:

The KELLY + PARTNERS Group has offices throughout New South Wales. To
meet the purposes for which your personal information has been
collected we may disclose your information to others in the KELLY +
PARTNERS Group.

(b) Disclosure overseas:

KELLY + PARTNERS
utilises some service providers overseas to process data and help
deliver services to you. We may disclose your personal information to
these providers from time to time. Such overseas disclosure would be to
India or another country as advised. When required, your personal
information will only be disclosed to an overseas person or business in
the following circumstances:

Where the overseas recipient has signed a contract with us which
creates legal obligations to comply with Australian Privacy Law (i.e.
the APPs);

If the recipient is subject to similar privacy law as Australian
privacy law, and you are able to personally access avenues to enforce
the protection of those laws;

If you provide written consent for KELLY + PARTNERS to disclose the information after we provide you with full information; or

If the disclosure is required or authorised by or under an Australian law or a court/tribunal order.

On collection of your personal information, we will inform you
whether it is likely we will disclose the information to an overseas
recipient and, if so, where those recipients are likely to be located.

6. Privacy on our websites

The KELLY + PARTNERS website uses Google Analytics to analyse
aggregate user behaviour. Google Analytics uses first party cookies,
which are text files placed on your computer for the purpose of
anonymously identifying your session. These cookies are not used to
grant KELLY + PARTNERS access to your personally identifiable
information. Non-identifiable information (such as the pages you visit)
may be tracked. By directing your browser to delete your cookies, this
data will be erased. For more information about Google Analytics, please
follow the links provided on our website.

The information is collected using first party cookies, meaning that
only KELLY + PARTNERS is able to access your information. Your
information may be aggregated with information from other users for the
purpose of improving our website and offerings. We will not associate
any data gathered from our website with any personally identifiable
information, unless you explicitly submit that information (e.g. your
email address) via our online information form.

Any links to third party websites on Kelly Partners website are not covered by our privacy policy.

7. Direct marketing

KELLY + PARTNERS may engage in direct marketing to you from time to time.

When required, your personal information will only be used or
disclosed for direct marketing where the information is not sensitive
information, is collected directly from you and there is an easy means
to opt out of such marketing (and such an opt out request has not been
made) in the following circumstances:

Where you would expect KELLY + PARTNERS to use or disclose the information for direct marketing purposes; or

You have consented to the use or disclosure of the information for direct marketing purposes.

8. Access to personal information

You have the right to access any personal information regarding you
that KELLY + PARTNERS holds. This is subject to some limited exceptions,
which the Privacy Officer can provide further information on.

Such requests should be made in writing to the Privacy Officer. We
will acknowledge your request within 14 days and respond to it within a
reasonable time.

KELLY + PARTNERS may charge a fee only to cover the cost of locating,
retrieving, reviewing and copying any material requested. We will not
charge any fee to make the request or to for us to give effect to the
request.

Responding to your request:

If your request is approved, we will provide you with access to the
information in the manner requested if it is reasonable and practicable
to do so.

9. Correction of personal information

KELLY + PARTNERS endeavours to ensure that the personal information it holds is accurate and up-to-date.

You are able to make a request to correct the information by
contacting our Privacy Officer, or by telephoning or emailing us with
your corrected information. In some limited circumstances your request
may be refused or partially refused.

10. Procedure if your request to access or correct is refused

There may be limited circumstances where your request is refused or partially refused.

If this occurs we will give you a written notice that sets out:

The reasons for the refusal, including the reasons why access
cannot be granted in an alternative way (except where it would be
unreasonable to provide those reasons);

How to make a complaint about the refusal;

Any other matter as prescribed by the regulations.

If your request to correct is refused you have the option of
submitting a statement associated with your personal information. For
more information contact the Privacy Officer.

11. How to make a complaint

If you consider that any action of KELLY + PARTNERS breaches this
policy or the Australian Privacy Principles, you are able to make a
complaint. Once we have received your complaint, it will be assessed and
acted upon within a reasonable time.

To make a complaint please contact our
Privacy Officer. If you are not satisfied with our response to your
complaint, you may contact the Office of the Privacy Commissioner.

Kelly+Partners

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Each office of Kelly Partners (Office) is a separate legal entity. Services are delivered independently by each Office. These Offices are not members of one national partnership or otherwise legal partners with each other, nor is any one Office responsible for the services or activities of any other.

Kelly Partners Group Holdings Limited (KPGH) is not responsible or liable for any acts or omissions of an Office and specifically disclaims any and all responsibility or liability for acts or omissions of an Office.